On December 21, 2011, the Bureau of Consumer Financial Protection (CFPB) published an interim rule in the Federal Register (76 FR 79308-01), substantively compiling the various rules issued by various agencies which enforce the Fair Credit Reporting Act (codified as 15 USCA §§1681 et seq.), including Regulation V (12 CFR §§222.1 et seq.), and using this compilation to create its own Regulation V (12 CFR §§1022.1 et seq.).
Included in this compilation were the Model H forms issued by the Federal Reserve Board (FRB) and the identical Model B forms issued by the Federal Trade Commission (FTC) for risk-based pricing. The CFPB versions of these forms are now set forth in 12 CFR Pt. 1022, App. H. They are identical to the FRB and FTC forms, with the exception that the contact information for obtaining more information about credit reports has been changed from these agencies to the CFPB.
The rule regarding this change is set forth under the list of acceptable changes to these documents (which, apparently, reference the earlier versions from the FRB and the FTC), as follows:
“Acceptable changes include, for example:
(ix) Until January 1, 2013, substituting ‘For more information about credit reports and your rights under Federal law, visit the Federal Reserve Board’s Web site at www.federalreserve.gov, or the Federal Trade Commission’s Web site at www.ftc.gov.” for “For more information about credit reports and your rights under Federal law, visit the Consumer Financial Protection Bureau’s Web site at www.consumerfinance.gov/learnmore.’” (Ibid. [a])
Starting January 1, 2013, these forms must refer to the CFPB’s contact information. Rather than wait until then to instigate this change, DocuTech is taking a pro-active approach and will be substituting the contact information for the FRB and FTC with that of the CFPB on its version of the H-3 and H-5 Forms (Cx15312) now.
This change will take effect on July 4, 2012. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
June 26, 2012